SAFT America, Inc. - Executive Summary |
|
SAFT America, Inc. has adopted rigorous safety, accidental release prevention and emergency response procedures into its overall policies. Senior management is committed to these policies. This commitment is evidenced through support and direction given to both safety and environmental programs. This commitment is further exemplified through the lack of accidents, injuries and lost time accidents. There have been only two lost time accidents in the past five years. In addition to the above comments and statistical review, SAFT America, Inc. has prepared a Process Safety Management (PSM) plan in response to regulations promulgated by the Occupational Safety and Health Administration (OSHA) as part of 29 CFR 1910.119. This regulation states that if there are certain chemicals present at a facility in amounts greater than specific limits; then, the facility must prepare a PSM program. SAFT America, Inc. has one chemical, sulfur dioxide, on-site in greater than planning quantities; consequently, a Process Safety Management (PSM) plan has been prepared. The PSM is incorporated into this document by reference. At this facility, SAFT America, Inc. manufactures specialty batteries, for civilian and military use. Some of these specialty batteries utilize sulfur dioxide as a battery component. There are other materials which are also incorporated into the battery with the sulfur dioxide as electrolyte. Larger battery systems are typically built by combining several battery cells which are connected through small circuit boards. All of the components (cells, wiring and circuit board) are then encapsulated in a tough plastic box for use in remote locations. SAFT America, Inc. is located on about twenty three acres of land located north of the Town of Valdese, North Carolina, off Lovelady Road. A fence surrounds the entire facility with twenty four hour security guards on duty. The facility is designed primarily for mechanical manufacturing, with a small chemic al mixing and storage area. The chemical area allows for (a) the receipt and storage of sulfur dioxide, (b) the receipt and storage of electrolyte material, (c) the mixing of electrolyte materials and sulfur dioxide prior to injection into the battery, and (d) a wet scrubber and its supporting equipment for the pollution control of any fugitive emissions of sulfur dioxide. There are only two bulk chemical storage tanks on site; one for isopropyl alcohol that is used in another battery process, and the other is for sulfur dioxide. The sulfur dioxide storage tank is a nominal 5,000 gallon capacity, and is located inside a separate, isolated room which has its own diking system. The room also has its own sprinkling system. The sulfur dioxide tank has several instruments attached which sense internal pressure, temperature, and liquid level indication. The sulfur dioxide tank rests on load cells which can measure the total weight of the tank and contents. This helps ensure against overfilling the tank. The tank also has pressure relief valves which will vent the tank if excessive pressure develops. All of the vented gaseous sulfur dioxide, either from filling operations or from pressure relief valve venting, is collected and routed through the wet scrubber prior to discharge. Both the tank and its appurtenant piping are routinely examined on a daily and weekly basis. Additionally, the sulfur dioxide storage tank has been checked for wall thickness measurements and roughness to ensure tank integrity. Sulfur dioxide is delivered to the facility in tanker trucks, and is unloaded into the sulfur dioxide storage tank. There is a specific unloading process posted at the facility. The unloading process involves connecting liquid transfer (loading) and vapor transfer (return) piping on proper sequence. The reason for return piping is to close the loop, impound all sulfur dioxide vapors, and not allow escape of any material. It is also a requirement that all sul fur dioxide delivery truck drivers be trained in hazardous materials handling and specifically in sulfur dioxide handling. All deliveries are monitored by SAFT America, Inc. personnel. Sulfur dioxide is transferred from the bulk storage tank through a designed and engineered piping system. There are piping leak detection devices mounted at small intervals along the piping path. In addition, there are sulfur dioxide area monitors located in the electrolyte mix room and in the battery fill room. All of these detection systems are connected to an alarm system that will warn employees of the presence of sulfur dioxide. The alarm point for the area detectors is 0.5 ppm, which are 25% of the mandated OSHA eight hour time period exposure level of 2 ppm (OSHA PEL of 2 ppm). Because of the relatively large quantity of sulfur dioxide handled, the low PEL, and management's commitment to safety; SAFT America, Inc. has instituted rigorous safety planning and procedures for the safe handling and use of sulfur dioxide. Process Safety Management (PSM) has already examined several of the safety practices and procedures in place for employees. In addition, due to the fact that there may be off specification material and/or other hazardous wastes, SAFT America, Inc. has established an emergency first response system which complements the response capability of the local fire department. Our emergency first response system is staffed with personnel that have completed mandatory OSHA training, and have had additional training in self-contained breathing apparatus and incident command training. In addition, all employees have been trained in hazard communication, hazardous materials handling (where applicable), hazardous waste handling (where applicable), lock out/tag out, equipment emergency shutdown procedures, etc. Further, all employees have been instructed as to means of egress and congregation points. Evacuation routes are posted throughout the facility. The worse c ase scenario for the release of sulfur dioxide is breach of the bulk storage tank. This is not likely, but could occur in a fire or explosive situation. If this were to occur, the worse case scenario would be the release of the entire contents of the tank. The release of this quantity of material within a diked area and within a building was used in conjunction with the US EPA published Off-site Consequence Analysis Guidance document via the RMP*Comp? software to estimate the impact of a release. Under this worst case release scenario, the sulfur dioxide released would reach off-site endpoints and nearby public receptors. Although our planning includes this scenario, we firmly believe that a worse case release would be much less likely to impact an area of the size calculated by the RMP*Comp? release model. Release models used for our own planning purposes prior to the RMP regulations indicated that an evacuation distance of less than one-sixth of the RMP*Comp? worst case release scenario distance in the down wind direction is much more likely for a worst case release scenario. The alternative case scenarios are typically based on past incidences that have occurred at the facility involving the regulated substance and its process. Because there have been no such incidences in the fifteen operating year history of this process, a different approach was necessary for this facility. Two scenarios were chosen from the most likely accidental release scenarios in the PSM Process Hazard Analysis. The alternative case scenarios are more likely to be the type of emergencies that the facility and its responders will encounter. The first scenario involves a puncture in the tank, and the second scenario involves a pipe leak / transfer hose rupture. One alternative scenario involves a one square inch area puncture in the side of the tank at twelve inches below the liquid level of sulfur dioxide in the tank. If this situation occurred, the release may reach off-site e ndpoints and nearby public receptors. The second alternative scenario involves a two inch diameter hose used in the bulk liquid transfer of the sulfur dioxide from a tanker truck to the storage tank. In the event of a rupture of the hose or sudden uncoupling of the hose from the tanker truck to the storage tank, the release may reach off-site endpoints and nearby public receptors. Because of the potential to impact off-site endpoints and public receptors, we have developed and continue to develop safety programs for the handling and use of sulfur dioxide. The rules and regulations with which we comply include 29 CFR 1910.119, Process Safety Management; 29 CFR 1910.38, Emergency Response and Fire Prevention; 40 CFR 112, Spill Prevention Control and Countermeasures; 40 CFR 265, Hazardous Waste Management; 49 CFR 171, Hazardous Materials Handling; 29 CFR 1910.134, Personal Protective Equipment; and other rules pertaining to air and water emissions. We have not had a reportable releas e of sulfur dioxide during the previous five years. Additionally, we have never had an accident nor incident involving sulfur dioxide that has had an off-site impact. Our emergency response program has been developed in conjunction with the local fire department. We have developed an emergency first response capability in house, and have asked the local fire department to be on immediate standby in the event of an incident or accident. Specific, documented training has been conducted for our emergency responders. Safety planning continues as an ongoing process. At this time, we do not expect to design and install any additional control devices nor mitigation procedures in relation to the sulfur dioxide. |